Australia: Integrity rule law companion ruling finalized
In April 2019, Australian Taxation Office (ATO) released a draft Law Companion Ruling on the Organization for Economic Cooperation and Development (OECD) hybrid mismatch rules related to integrity rule. The ATO have now released draft LCR
See MoreGreece: Finance Ministry published a Bill regarding anti-hybrid rules for public consultation
On 7 July 2020, the Ministry of Finance published a draft bill related to the transposition of anti-hybrid rules for public consultation. This Bill includes a new article, Article 50 to amend the Article 66B and covers to the extent in where a
See MoreCyprus Gazettes EU Anti-Tax Avoidance Directive
After the partial adoption of the EU Anti-Tax Avoidance Directive (ATAD I) of 12 July 2016 in 2019, on 19 June 2020 the Parliament of Cyprus voted into law the remaining provisions of ATAD I, as well as the provisions of the EU ATAD II of
See MoreCyprus: House of Representatives passed the law to implement EU ATAD
On 19 June 2020, the Cyprus Parliament adopted the law to implement the provisions EU Anti-Tax Avoidance Directive (ATAD I) with respect to exit taxation rules, as well as, the provisions of the amending Directive (ATAD II) with respect to
See MorePoland: Parliament passes a law implementing ATADII & DAC 6
On 18 June 2020, the higher chamber of the parliament passed a bill implementing the rules related to hybrid mismatches with third countries (ATAD II) and completing the transposition of the DAC 6 rules in its domestic legislation. Under the
See MoreUkraine: President signs law to implement BEPS and other provisions
On 21 May 2020, the President of Ukraine signed Law No. 466-IX (Draft Law No.1210) “On Amendments to the Tax Code of Ukraine on Improvement of Tax Administration, Elimination of Technical and Logical Inconsistencies in Tax Legislation", which was
See MoreAustralia: ATO concerns over mischaracterized financial arrangements
On 25 May 2020, the Australian Taxation Office (ATO) issued Taxpayer Alert (TA) 2020/2, in relation to mischaracterised arrangements and schemes connected with direct foreign investment into Australian businesses. ATO is concerned that
See MoreAustralia: New proposals on Hybrid mismatch rule
On 13 May 2020, the Treasury Laws Amendment Bill 2020 was presented in the House of Representatives that would make technical changes to the hybrid mismatch rules addressing integrity of income tax laws and their application to multinational
See MoreIceland: Parliament passes a bill to amend various taxes
On 6 May 2020, the Icelandic Parliament passed a Bill No.1329 amending income, withholding, excise, and VAT laws. The bill includes the amendments for corporate taxpayers in relation to the ISK 100 million safe harbor threshold for Iceland's
See MoreFrance: Tax authority publishes final guidelines for ATAD interest deduction limitations
On 13 May 2020, the tax authority published final guidelines regarding restrictions on interest deduction, including the amendments introduced by the Finance Law for 2019 to implement the EU Anti-Tax Avoidance Directive (ATAD). In accordance with
See MoreBelgium clarifies interest restriction rule due to COVID-19 pandemic
On 5 May 2020, the tax authority of Belgium published Circular No. 2020/C/62 providing new clarifications on the “grandfathering” rule, under the interest deduction limitation rule, loans made before 17 June 2016 are excluded from the scope of
See MoreSweden: Tax agency implements the OECD principles on financial transactions
On 24 April 2020, the Swedish tax agency has updated the financial transaction page. In February 2020, the OECD published a new Chapter X of the guidelines on financial transactions. Financial transactions between companies within a group are
See MoreMalta: Parliament enacts the Budget Measures Implementation Act 2020
On 20 March 2020, the Maltese Parliament has enacted the Budget Measures Implementation Act 2020. Through the enactment of this legislation, amendments were made to the Income Tax Act (ITA), Value Added Tax Act (VATA), Income Tax Management Act
See MoreLuxembourg issues Draft Law on the deduction of interest and royalties expenses
On 30 March 2020, the Luxembourg government has presented a Draft Law N°7547 to the Parliament introducing a non-deductibility of interest or royalties paid to associate enterprises established in countries that are “blacklisted” as being
See MoreCOVID-19: US passes Coronavirus Aid, Relief, and Economic Security (CARES) Act
On 19 March 2020, the US Senate Finance Committee submitted proposals for the third round of legislative measures in response to the economic impact of the coronavirus disease (COVID-19) pandemic. The Coronavirus Aid, Relief, and Economic Security
See MoreUK: Public consultation on hybrid mismatches rule
On 19 March 2020, the tax authority the United Kingdom has issued a consultation document for public comments on the impact of the double deduction rules and the acting together rules within the hybrid and other mismatches regime at Part 6A of the
See MoreSouth Africa: Finance Minister delivers draft Budget for 2020-2021
On 26 February 2020, the Finance Minister, Tito Mboweni, delivered National Budget for the year 2020-2021. Some provisions of budget 2020-2021 include: Corporate income tax The standard corporate income tax rate was proposed to remain
See MoreLatvia implements EU ATAD hybrid mismatch measures
On 11 February 2020, Latvia published the Law of 30 January 2020 on Amendments to the Corporate Income Tax Act in the official gazette. The law includes the provision for the implementation of the hybrid mismatch measures of the EU Anti-Tax
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